The government raises the levy on tobacco, and sellers raise their prices by the full amount. Buyers carry on buying. Who has paid the tax? On whom did it fall first, who bears it in the end, and what happened to sales? One short scenario uses most of the vocabulary the exam tests: tax base, tax yield, tax rate, incidence, burden, impact, shift and effect.
The same topic asks you to classify taxes three ways (by the subject, by the base and by the way the burden is spread) and to list the qualities of a good tax system.
This topic covers the Nigerian tax system, the principles of a good tax system, the classification of taxes, direct and indirect taxes with their merits and demerits, proportional, progressive and regressive taxes, the difference between taxes and levies, and the basic concepts of taxation. The previous topic covered what tax is and its objectives. The next covers the sources of tax law.
In 30 seconds
Tax system: policy, laws and administration. Principles: certainty, economy in collection, convenience, efficiency, equity (vertical and horizontal), flexibility and neutrality. Classified by the subject: direct (company income tax, PAYE, capital gains tax) and indirect (VAT, excise, import and export duties). By the base: capital, income and consumption. By the burden: proportional (company income tax), progressive (PAYE) and regressive (VAT). Concepts: base, yield, rate, incidence, burden, impact, shift (swap) and effect.
A tax is compulsory and backed by law; a levy can be a fee, or a fine or penalty.
Key terms in plain English
| Term | What it means |
|---|---|
| Tax base | The measure on which tax is assessed: the part of income or property expected to suffer tax |
| Tax yield | The revenue collected from taxing the base |
| Tax rate | The ratio, usually a percentage, at which a person or business is taxed |
| Tax incidence | How the burden of a tax is divided between buyers and sellers |
| Tax burden | The amount of income, property or consumption tax levied on a person or business |
| Tax impact | The effect of a tax on the production or consumption of the taxed product |
| Tax shift (tax swap) | A change that cuts some taxes and raises others, keeping total revenue the same |
| Tax effect | The consequences of a specific tax situation for a particular taxpayer |
Syllabus check
This topic is in syllabus area A, introduction to taxation, tax administration and ethics (20% of marks). It covers:
- the Nigerian tax system and the principles of a good one;
- classification of taxes and the differences between taxes and levies;
- basic concepts in taxation.
CAMA 2020 and the tax system
The Companies and Allied Matters Act 2020 (CAMA 2020) is the company law of Nigeria. The sections below apply to this topic.
| Section | What it says | Link to this topic |
|---|---|---|
| s. 377(1) and s. 378 | Directors prepare financial statements that give a true and fair view | Taxes on income start from the accounting profit, so the tax base is only as reliable as the accounts |
| s. 305 and s. 308 | Directors must act in good faith and with the care, diligence and skill of a prudent director | Directors must know which taxes the company bears and which it collects for others, such as VAT and PAYE |
The rules in more depth
The Nigerian tax system
A tax system has three parts: the policy, the tax laws and the tax administration.
- Tax policy is a set of general statements of intention that guide the thinking and action of everyone concerned towards the set goals. It includes moving the emphasis from income tax to consumption tax, which is less prone to evasion; reducing individual tax burdens, widening the tax net and encouraging savings and investment; introducing self-assessment to bring taxpayers into the assessment process; and moving from coercion towards voluntary compliance.
- Tax laws include the Personal Income Tax Act, the Companies Income Tax Act, the Capital Gains Tax Act, the Value Added Tax Act, the Tertiary Education Trust Fund Act, the Stamp Duties Act and the Petroleum Industry Act 2021 (all for periods before 2026). The Constitution gives the legislation of income tax, personal or corporate, to the Federal Government to promote uniformity, but the administration is shared by the three tiers of government. Laws are reviewed to match social, political and economic change, and non-compliance attracts penalties.
- Tax administration is the practical interpretation and application of the laws, by the Federal, State and Local Governments. The FIRS Board, the State Boards of Internal Revenue and the Local Government Revenue Committees are set up under federal laws.
A good tax system should create jobs and a tax increase should lead to the arrest of wasteful spending. No one pays tax with a smile, but tax makes the private sector pay for services given by the public sector. It shapes and directs economic activity, redistributes resources and finances social welfare. A “tax cut” does not mean government gives something back.
It means government takes less of people’s money, so that they can spend more of it as they choose.
Principles of a good tax system
| Principle | Meaning |
|---|---|
| Certainty | The taxpayer knows the exact amount to pay, the basis, the rate and the authority to pay to |
| Economy in collection cost | The cost of collecting tax is low compared with the tax collected |
| Convenience | The method and timing of payment suit the taxpayer, and taxpayers are easy to locate |
| Efficiency | Compliance and administrative costs stay below the revenue raised, to avoid resentment, especially among small earners |
| Equity | Vertical equity: the rich pay more than the poor. Horizontal equity: people in similar situations are treated alike |
| Flexibility | Rates can be changed easily, so tax serves as a fiscal tool |
| Neutrality | Tax does not distort economic choices or cause excess burden |
Classification of taxes
Taxes can be classified from the perspective of the tax subject, the tax base or the distribution of the burden.
By the subject: direct and indirect. A direct tax is levied directly on the taxpayer’s income, for example company income tax, PAYE and capital gains tax. An indirect tax is levied on goods and services. It may be specific, a fixed amount per unit, or ad valorem, a percentage of the cost. Examples are import and export duties, excise duties and VAT.
| Direct tax | Indirect tax | |
|---|---|---|
| Merits | Lower cost of collection; more equitable, since higher earners bear more; easier to ascertain incidence | Good source of revenue; easily adjusted; checks consumption of undesirable goods; protects infant industries; harder to evade |
| Demerits | May discourage hard work; invites evasion where rates are high; may cause unrest because the taxpayer bears the whole burden | Higher cost of collection; revenue loss where officials collude with taxpayers; may discourage investment in local industry, for example through high export or excise duties |
By the base. The base may be capital (capital gains tax), income (personal income tax and company income tax) or consumption (VAT and excise duties).
By the distribution of the burden.
- Proportional: the same percentage of income, such as company income tax and capital gains tax.
- Progressive: the more the taxpayer earns, the more he pays, such as PAYE.
- Regressive: the person with a smaller income pays a greater percentage than one with a higher income. All flat rates are regressive in effect, and VAT is the example.
Taxes and levies
Nightingale (1997) describes tax as a compulsory contribution imposed by government, for which taxpayers may get nothing identifiable in return, though they benefit from living in a relatively educated, healthy and safe society. Tax is not charged for a specific service.
Levies are paid for specific services, as with a fee such as a court fee, which covers the cost of a service done mainly in the public interest but giving the payer a special advantage. Fines and penalties are another form of levy: they punish breaches of law and do not raise revenue. All taxes are levies, since they are imposed, but not all levies are taxes.
The tax on company profits in section 9(1) of the Companies Income Tax Act is a tax, while the penalty and fine in section 85(1) are only a levy. A tax, like a levy, is compulsory, but it is not meant to punish. A tax must be backed by a written law, and if a law is invalid then a charge made under it cannot be a tax.
If a charge rests on a valid tax law, it is a tax whatever it is called.
Basic concepts in taxation
| Concept | Meaning | Example |
|---|---|---|
| Tax base | The measure on which liability is based | Taxable profit or the value of goods sold |
| Tax yield | Revenue derived from administering the tax | Rate × base |
| Tax rate | The ratio at which a person or business is taxed | VAT at 7.5% |
| Tax incidence | The division of the burden between buyers and sellers | A tobacco levy fully passed to buyers who keep buying |
| Tax burden | The tax levied on a person or business, which varies with income, place and rates | PAYE deducted from a pay slip |
| Tax impact | The effect on production or consumption of the taxed product | A higher tobacco levy cuts tobacco sales |
| Tax shift (swap) | Some taxes cut and others raised, revenue unchanged | Lower income tax, higher consumption tax |
| Tax effect | Consequences of a tax scenario for a particular taxpayer | The result of a rate change on one company |
The position from 2026
The concepts and classifications do not change. For periods from 2026 the laws are the Nigeria Tax Act 2025 and the Nigeria Tax Administration Act 2025, and the tax authority is the Nigeria Revenue Service. The Nigeria Tax Act reduces the number of levies by replacing several with the 4% development levy, which fits the policy aim of fewer, broader taxes.
Worked examples
Example 1: classify. Classify PAYE, VAT, capital gains tax and excise duty by subject, base and burden.
- PAYE: direct, income base, progressive.
- VAT: indirect, consumption base, regressive in effect.
- Capital gains tax: direct, capital base, proportional.
- Excise duty: indirect, consumption base.
Example 2: incidence. A ₦100 tax per carton is put on a drink. The producer raises the price by ₦100 and sales do not fall.
- The producer collects and pays the tax.
- The incidence falls wholly on the buyers, because the price rose by the full tax and demand did not change.
- The impact on consumption is nil in this case.
Example 3: progressive or regressive? A flat tax of ₦5,000 is paid by a person earning ₦50,000 and by one earning ₦500,000.
- First person.
5,000 ÷ 50,000 = 10% of income. - Second person.
5,000 ÷ 500,000 = 1% of income. - The smaller earner pays a larger share, so the tax is regressive.
How to score full marks
- Give a one-line definition and an example for each concept.
- Set out merits and demerits of direct and indirect taxes in two columns.
- List the seven principles with a phrase each.
- Link tax to levy by the rule that every tax is a levy but not every levy is a tax.
Common mistakes in the exam
- Mixing impact and incidence: impact is the effect on output or consumption, incidence is who bears the burden.
- Calling VAT progressive.
- Giving only merits, or only demerits.
- Omitting the two kinds of equity.
Quick revision
- Seven principles: certainty, economy, convenience, efficiency, equity, flexibility, neutrality.
- Direct: income and capital. Indirect: goods and services.
- Proportional, progressive, regressive.
- Concepts: base, yield, rate, incidence, burden, impact, shift, effect.
Practice questions
Questions 1 to 10 are multiple choice. Questions 11 to 13 are written. Try each before opening the answer.
Question 1. A tax system has three parts, namely:
- Rates, base and yield
- Policy, laws and administration
- Income, capital and consumption
- Federal, State and Local
Show the answer
B. The tax system is the policy, the tax laws and the administration.
Question 2. Vertical equity means:
- Equal treatment of people in the same situation
- The rich pay more than the poor
- Flat rates for all
- No tax for the poor
Show the answer
B. Horizontal equity is equal treatment of people in similar situations.
Question 3. Which is an indirect tax?
- PAYE
- Capital gains tax
- Excise duty
- Company income tax
Show the answer
C. Excise duties are levied on goods.
Question 4. A tax of a fixed amount per unit of a commodity is:
- Ad valorem
- Specific
- Proportional
- Progressive
Show the answer
B. A specific tax is a fixed sum per unit. Ad valorem is a percentage of cost.
Question 5. A tax where the more the taxpayer earns, the more he pays is:
- Regressive
- Proportional
- Progressive
- Neutral
Show the answer
C. PAYE is the example.
Question 6. In this course VAT is classified as:
- Progressive
- Proportional
- Regressive
- Capital
Show the answer
C. Flat rates are regressive, and VAT is the example.
Question 7. The effect of a tax on the production or consumption of the taxed product is its:
- Incidence
- Impact
- Burden
- Yield
Show the answer
B. Raising the levy on tobacco might reduce tobacco sales.
Question 8. A change that cuts some taxes and raises others, with the same total revenue, is a:
- Tax cut
- Tax shift
- Tax effect
- Tax rate
Show the answer
B. A tax shift, also called a tax swap.
Question 9. Which is a merit of direct tax?
- Hard to evade
- Easier to ascertain incidence
- Can protect infant industries
- Checks undesirable consumption
Show the answer
B. The others are merits of indirect taxes.
Question 10. Which statement is correct?
- All levies are taxes
- All taxes are levies but not all levies are taxes
- Fines are taxes
- Fees are taxes
Show the answer
B. Fines, penalties and fees are levies but not taxes.
Question 11 (10 marks). (a) Explain the seven principles of a good tax system. (7 marks) (b) Distinguish a tax from a levy. (3 marks)
Question 12 (10 marks). (a) Classify taxes by the subject, base and distribution of the burden, with examples. (6 marks) (b) State two merits and two demerits of indirect taxes. (4 marks)
Question 13 (10 marks). Explain the following concepts: tax base, tax yield, tax rate, tax incidence, tax burden, tax impact, tax shift and tax effect. (10 marks)
Model answers
Show the model answer to Question 11
(a) Principles (7 marks). Certainty; economy in collection cost; convenience; efficiency; equity, vertical and horizontal; flexibility; neutrality, each explained in one line. (1 each)
(b) Tax and levy (3 marks). A tax is compulsory and backed by law and is not paid for a specific service. (1½) A levy is paid for a specific service, such as a fee, or punishes a breach, such as a fine. Every tax is a levy but not every levy is a tax. (1½)
Show the model answer to Question 12
(a) Classification (6 marks). By subject: direct (PAYE) and indirect (VAT). (2) By base: capital, income and consumption. (2) By burden: proportional, progressive and regressive. (2)
(b) Indirect taxes (4 marks). Merits: good revenue source; easily adjusted; checks undesirable consumption; hard to evade. (2) Demerits: higher collection cost; revenue lost through collusion; may discourage local investment. (2)
Show the model answer to Question 13
Tax base: the measure on which tax liability is based. Tax yield: revenue derived from taxing the base. Tax rate: the ratio at which a person or business is taxed. Tax incidence: how the burden is divided between buyers and sellers. Tax burden: the amount of tax levied on a person or business. Tax impact: the effect on production or consumption of the product taxed.
Tax shift: cutting some taxes and raising others with total revenue unchanged. Tax effect: the consequences of a tax situation for a particular taxpayer. (1¼ each)
Pathfinder on Principles, classification of taxes, tax and levy, and base, yield, rate, incidence, burden, impact, shift and effect
These are the ICAN Pathfinder questions that test this topic. ICAN owns the questions and the suggested solutions, so we point you to them and do not copy them. Open your Pathfinder, attempt each question under exam conditions, then check your answer against the notes above.
Revise first: Classification of taxes
Revise first: Classification of taxes
Source: ICAN Pathfinder, Taxation. Diets covered: May 2026 and November 2025.
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